California Case Summaries

People v. Manjarrez — Court of Appeal affirms assault conviction and nine-year sentence after independent Wende review, ordering correction of the abstract of judgment

Unreported / Non-Citable

Case
P. v. Manjarrez CA5 filed 10/13/26
Court
5th District Court of Appeal
Judge
Franson; Meehan; Snauffer
Date Decided
2026-10-13
Docket No.
F089518
Status
Unreported / Non-Citable
Topics
Wende review, independent record review, assault with a deadly weapon, great bodily injury enhancement, Three Strikes law, Romero motion, abstract of judgment, clerical error, judgment affirmed

Background

Paul Michael Manjarrez was charged in Fresno County with assault with a deadly weapon, personal infliction of great bodily injury, and a prior serious or violent juvenile adjudication under the Three Strikes law. He rejected a proposed resolution involving an amended assault charge, dismissal of the great-bodily-injury enhancement, and a six-year sentence. After the prosecution’s case-in-chief, Manjarrez moved for acquittal under section 1118.1; the trial court denied the motion, and the defense rested without presenting any evidence. The jury convicted him of assault with a deadly weapon and found the great-bodily-injury allegation true. Manjarrez separately waived a jury trial on the prior-strike allegation and admitted a 2014 juvenile adjudication for murder.

The prosecution’s evidence concerned a May 30, 2024 confrontation at the residence where Manjarrez’s girlfriend and their daughter lived. Witnesses described an argument that began outside and continued after Manjarrez followed R.A. into the apartment. R.A. subsequently reported that Manjarrez had stabbed him, and an officer observed wounds under his chin and on his arm. R.A. later told an officer that Manjarrez charged at him and slashed him repeatedly with a boxcutter after he fell. Officers recovered a crescent wrench and a kitchen knife in the yard, and Manjarrez was arrested three months later.

On March 18, 2025, the trial court denied Manjarrez’s Romero motion to strike the prior juvenile adjudication. It imposed the three-year middle term for assault, doubled that term to six years under the Three Strikes law, and added three years for the great-bodily-injury enhancement, producing a nine-year determinate prison sentence. The court credited Manjarrez with 212 days of actual presentence custody credit and 31 days of conduct credit, for a total of 243 days. It imposed a $1,800 restitution fine and a separate $1,800 parole revocation restitution fine. The court found Manjarrez lacked the ability to pay the court operations assessment and the court facilities assessment and did not impose them. He filed a timely appeal.

The Court’s Holding

Appellate counsel filed a brief under People v. Wende requesting independent review of the record and declared that Manjarrez had been advised of his right to submit his own brief. By letter dated July 7, 2026, the Court of Appeal invited Manjarrez to submit additional briefing within 30 days, but he filed no response. The court reviewed the entire record under Wende and People v. Kelly and found no arguable error that would result in a disposition more favorable to Manjarrez. Its discussion specifically stated that the examination revealed no evidence of ineffective assistance of counsel or any other arguable error that would result in a disposition more favorable to him.

The court nevertheless identified a clerical problem in the abstract of judgment: it stated that Manjarrez had been convicted by plea even though the jury convicted him. Citing People v. Baker and In re Candelario, the court ordered that error corrected. This was a limited correction of the judgment’s documentation, not a reduction of the conviction, enhancement, or sentence.

The disposition affirmed the judgment and directed the trial court to issue an amended abstract reflecting that Manjarrez was convicted by jury rather than by plea and to forward that amended abstract to the appropriate authorities. The opinion did not alter the nine-year term, the credits, or the fines.

Key Takeaways

  • Independent review of the entire appellate record revealed no arguable error that would result in a disposition more favorable to Manjarrez.
  • The Court of Appeal expressly found no evidence of ineffective assistance of counsel or any other arguable error that would result in a disposition more favorable to Manjarrez.
  • The jury conviction, great-bodily-injury finding, prior-strike consequences, and nine-year prison sentence remained intact.
  • The only ordered relief was correction and forwarding of an amended abstract of judgment showing that the conviction resulted from a jury verdict rather than a plea.
  • Manjarrez did not submit additional briefing after counsel’s Wende filing and the court’s July 7, 2026 invitation.

Why It Matters

The decision illustrates the two possible components of a Wende disposition: rejection of appellate claims after an independent record review and correction of a discrete clerical defect that does not change the underlying judgment. The court’s affirmance resolved the appeal without finding a basis to disturb the conviction or sentence, while its direction concerning the abstract ensured that the official sentencing document would accurately reflect how Manjarrez was convicted.

Read the full opinion (PDF) · Court docket

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